Privacy Policy - as of May 2018

At Lionvest Trading (UK) Ltd we take your privacy seriously and we respect your privacy and data protection rights. This privacy notice aims to give you information on how we collect and process your personal data. Please take time to read this privacy notice in full, to ensure that you understand and are happy with how we collect and process your personal data.

Please note we do not collect or process any sensitive data, children’s data or criminal convictions and offences data.

Controller

Lionvest Trading (UK) Ltd is responsible and the controller of all data managed through our services and website. We have appointed a DPO (Data Protection Officer). Who is responsible for overseeing questions in relation to this privacy policy and other responsibility’s relating to GDPR and data protection including any requests to exercise your legal rights regarding the data we hold and process.

Contact Details

Our full contact details are as follows:

Lionvest Trading (UK) Ltd
Unit A1 Portland Business Park
Portland Road
Hove
East Sussex
BN3 5RY

Tel: 01273 426570

Email: [email protected]

Website: www.lionvest.co.uk

Company Reg No: 03484595

VAT Reg No: 711 7452 55

You have the right to make a complaint at any time to the ICO (Information Commissioner’s Office), the supervisory authority for data protection issues in the UK. Their contact details are as follows:

Tel: 03931 231113

Website: www.ico.org.uk

However, we would appreciate the chance to deal with any of your concerns before you approach the ICO, so please feel free to contact as regarding any issues you may have.

Changes To This Privacy Notice And Changes To Your Details

We will need to update this privacy policy from time to time as the law and/or our business changes and develops. We will endeavour to tell you in advance by sending a service message to you if we hold your email address. Otherwise, please look out for any notification on our website and marketing materials that indicates we have changed our privacy policy.

It is important that the personal data that we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your dealings with us.

Third Party Links

Our Website and services may include links to third-party websites, plugins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party services and are not responsible for their privacy policies. When you leave our website and/or service, we encourage you to read the privacy policy of every website, plugin and application that you may visit.

The Personal Data We Process

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may process different kinds of personal data about you, which we have categorised as follows:

Identity Data: Including your name, username, account number and email address.

Contact Data: Including your billing address, delivery address, email address and telephone number.

Financial Data: Including credit limit and bank details.

Transaction Data: Including the details of the products and services you have purchased and the date, time and location of the sale and your purchasing activity.

Technical Data: Including data we collect through your use of our website and services, where you came to our website from and where you went when you left our website, how often you visit and use our website, technical information about the devices you use to access our websites including your device’s unique identifying codes E.G. it’s “MAC” address, the relevant IP address, operating system and version, web Brower and version and geographic location.

Profile Data: Including your username, account number, purchases, your interests, your preferences, your feedback, your survey responses, your social media content (where this is in the public domain including posts, comments, pictures and video footage), profile information, insight from organisations that already hold information on you, such as credit reference agencies  and customer insight companies who give us their views on your current status as well as your possible preferences and behaviours.

Usage Data: Including information about how you use our website, services and products.

Marketing And Communication Data: Including your preferences in receiving marketing from us and our third parties, your communication preferences and information ion what you view, click and access in and through our marketing emails and website.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity in any way. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Where we need to collect personal data by law or under the terms of a contract we have with you and you fail to provide the data when requested, we may not be able to perform the contract we have or are trying to enter into with you (E.G. to provide you with our products or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

Profiling

We do, from time to time, process personal data about you in an automated way to evaluate certain personal aspects about you, to enable us to analyse and make predictions about your interests and how you are likely to interact with us. This is commonly referred to as profiling and it is our way of providing you with a more bespoke customer experience based on how we think you engage with us.

The personal data about you that we process for profiling purposes includes your identity data your contact data and your profile data. We do not process personal data about you for profiling purposes that consists of special category personal data. We process your personal data for profiling purposes for our legitimate interests as set below, which will inform you of the exact kind of profiling we do and what profiling means to you.

You also have the right to object to us processing your personal data for profiling.

How We Profile And The Logic We Use

We collect your personal data from several sources, including directly from you, which we then combine to create a view of your interactions with our services and products. Once we have this record we match multiple variables that are unique to you (such as name, email, postcode) to create an overall matched record. We then clean the record by comparing it with certain third-party reference files (such as the Post Office Address File and email validation services) to try to ensure that the record is as accurate as possible.

Once the record is cleaned, we add the record to our customer database and we start to build a behavioural profile about you, which details the products and services that you do and do not engage with. We also infer a visit to a product or service location so that we can gain a better understanding. In addition, we apply our algorithms or scoring models to the record to indicate how likely it will be that you will engage with a product or service in the future. We then segment our overall database to create a customer base for each product or service to determine those customers with a high likelihood to engage with a product or service and those who are unlikely to engage with a product or service. Your record may be in more than one segmented element of the database, for example, you may be high likelihood for 3 of our products and low likelihood for 2 of our products within your catchment area.

Finally, to ensure that you get the most relevant communications from us, we may use the above variables (if you have agreed to us sending you certain communications) to select an appropriate communication for you to receive, as well as ensuring that you receive the right content or offer. For example, our profiling will help us determine whether you may be more interested in our herringbone and chevron products as opposed to our plywood products. We enhance this information with data we have regarding the communications and promotions that you have or have not engaged with in the past.

Significance And Consequence Of The Profiling

The profiling we do enables us to better understand how you interact, or may interact, with our brands. It enables us to provide you with the most relevant information and to determine whether a product or service should be more tailored to people who do or are likely to engage with it. The profiling also helps us to improve our services and the offerings of our products and services depending on the demographic of existing or future customers.

How We Collect Your Personal Data

We use different methods to collect personal data from and about you including:

Direct Interactions: You may give us your identity, contact, financial, profile, marketing and communications data by filling in forms or by corresponding with us by post, phone, email, social media or any other method of communication. This includes personal data you provide when you purchase our products or services, open an account with us, request information from us and ask to reserve are marketing newsletters and information.

Social media Interactions: Our website and services may allow you to interact with them by using social media applications. This interaction may result in us collecting some of your social media content (including posts and comments, pictures and video footage). But only where this content is in the public domain and/or where this content has been sent by you to us in a private message via social media, and your technical profile and marketing and communication data.

Automated Technologies: As you interact with our website and services we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Other Third Parties And Publicly Available Sources: We may receive personal data about you from various third parties and public sources as set out below:

• Technical data from analytical providers such as Google, Bing, Yahoo and other network search information providers.
• Marketing and communications data and technical data from online advertising data providers such as Google and Mailchimp.
• Contact, Financial and transaction data from providers of technical, payment and delivery services.
• Profile data and marketing and communications data from social media providers such as Facebook, Twitter and Linkedin.
• Identity and contact data from publicly available sources such as Companies House and the Electoral Register.

How We Process Your Personal Data

We only process your personal data when allowed to do so by law. Most commonly, we will process your data:

• With your consent and please note that you have the right to withdraw your consent at any time by contacting us.
• Where we need to perform a contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Below will set out how we process your personal data. Please contact us if you would like further information about the specific basis for processing.

To Process And Deliver A Product Or Service That You Have Ordered From Us Including:

• When providing a sample or a quote.
• When processing an order that has been placed.
• When issuing a refund.
• When managing payment, fees and charges.
• When arranging a delivery of goods and services.
• When collecting and recovering money owed to us.
• Any other form of contractual arrangement that we agree to enter into with you.

Personal Data Used

• Identity data
• Contact data
• Financial data
• Transaction data

Basis For Processing

• Performance of a contract with you.
• Necessary for our legitimate interests, being to recover debts due to us.

To Process Your Registration With Us Including:

• To be able to make full use of our services.
• To be able to order products and services with us.

Personal Data

• Identity Data
• Contract Data
• Profile Data

Basis For Processing

• Performance of a contract with you.

To Tailor Our Direct Marketing To You And To Send You Direct Marketing Communications Via:

• Email
• Post

Personal Data

• Identity data
• Contact Data
• Technical Data
• Transaction Data
• Usage Data
• Profile Data
• Marketing and communications data

Basis For Processing

• In terms of tailoring our direct marketing, necessary for our legitimate interests, being to develop our business and inform our marketing strategy.
• In terms of sending direct marketing where you are a customer and have not previously opted out of receiving such direct marketing, as necessary for our legitimate interests, being to offer you relevant products and services related to what we have previously provided to you.
• In terms of sending direct marketing where you are not one of our customers, with your consent or otherwise give your details and provide consent when doing so.

To Enable You To Take Part In Prize Draws, Competitions And Surveys

Personal Data

• Identity data
• Contact data
• Usage data
• Profile data
• Marketing and communications data

Basis For Processing

• Performance of a contract with you.
• Necessary for our legitimate interests, being to study how customers use our products and services to develop them and grow our business.

To Understand Our Customers By Matching Common Information From Various Sources To Build A Profile Of You, This May Include:

• Understanding your habits, and the things you may like, dislike and may or may not be interested in.
• The way you interact with us, such as subscribing to our newsletter, promotions, offers and updates, completing surveys, entering competitions, browsing our website, interacting with us via social media and reviewing our products and service in public forums.
• Creating aggregated data.

Personal Data

• Identity data
• Contact Data
• Technical data
• Transaction data
• Usage data
• Profile data
• Marketing and communications data

Basis For Processing

• Necessary for our legitimate interests, being to develop our business, products, services, content and advertising campaigns to make these relevant for you and tracking the effectiveness of our advertising campaigns.

To Manage Our Relationship With You Which Includes:

• To notify you about changes to our privacy policy.
• To communicate with you about operational changes to our products, services and website.
• To gather feedback from you about our products, services, website etc from time to time.
• To respond to, deal with and address any question, suggestions, issues or complaints you have raised and reporting and analysis in respect of these.
• To respond to any social media reviews, posts or other public comments you make about us, our product, services, website or other activities.

Personal Data

• Identity data
• Contact data
• Profile data
• Marketing and communications data

Basis For Processing

• Performance of a contract with you.
• Necessary to comply with a legal obligation.
• Necessary for our legitimate interests (to keep our records updated and to study how customers use our products and services.

To Administer And Protect Our Business And Website And Offer Safe And Secure Use Of Our Products And Services Which Includes:

• The process of anonymising your information so that you are no longer identifiable to us, where we no longer need your data in an identifiable form.
• To provide safe access to our website.
• To power user security measures and services.
• To monitor security measures around our website to check they are not being abused or threatened.
• To protect you and our business against potential criminal behaviour, such as fraud.
• To administer troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data.

Personal Data

• Identity data
• Contact data
• Technical data
• Usage data
• Profile data
• Marketing and Communications data

Basis For Processing

• Performance of a contract with you.
• Necessary for our legitimate interests, being to run our business, ensure network security and prevent potential criminal behaviour.
• Necessary to comply with a legal obligation.

To Provide Information To Legal And Regulatory Bodies Where We Are Under A Legal Or Regulatory Obligation To Do So

Personal Data

• Identity data
• Contact data
• Technical data
• Transaction data
• Usage data
• Profile data
• Marketing and communications data

Basis For Processing

• Necessary to comply with a legal obligation.

How We Share Your Personal Data

We cannot run our business or provide many of the services and benefits you expect to receive without involving other people and businesses. We only share your information in accordance with the laws applicable to us and for the purposes set out above.

We share your personal data with:

• Service providers mainly acting as processors but sometimes as controllers who help us provide our websites and provide payment options. Such as IT companies who host our websites or payment services companies who enable you to use credit cards as a form of payment.
• Affiliated third parties acting as processors and controllers that provide services to us such as warehousing, delivery’s and market research.
• Any new business partners acting as both controllers or processors we may have over time for example if we enter into a joint venture, reorganisation, business merger or sale of part of our business, the other party may receive some or all of your information.
• Our professional advisors acting as controllers or processors
• The Police, HMRC, Health and Safety Executive and any other central or local authorities and government bodies acting as controllers and processors where we are required to do so to comply with our legal obligations.
• We also may share the information we collect with other third parties where we are legally obliged to do so.

International Transfers

Some of our external third parties are based outside of the EEA so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data outside the EEA, we ensure that a similar degree of protection is afforded to it by ensuring at least one of the following safeguards are implemented:

• We only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• We will use specific contracts approved by the European Commission which give personal data the same protection it has in the EEA.
• Where we use third parties based in the US, we may transfer personal data to them if they are part of the Privacy Shield which requires them to provide similar protection for personal data shared between the EEA and the US.

If you have any question in the relation to this section please contact [email protected]

How We Keep Your Personal Data Secure

We take the security of your personal data very seriously and have in place appropriate security measures at all times, including where we share your information with our suppliers and partners, to protect your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Our Retention Of Your Personal Data

We can only keep your personal data for as long as necessary for the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

The precise length of time we hold your personal data for varies depending on the individual circumstances, but in determining the appropriate retention period for personal data we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We regularly review our retention periods to ensure that we are not keeping your data for longer than is necessary. Details of retention periods for different aspects of your personal data are available by contacting us.

Your Rights

In certain circumstances, you may have the right to request access, transfer, rectification and/or erasure of the personal data that we process about you. You may also have the right to object to and/or restrict our processing of your personal data. Details of the rights you have are set out below.

• Human Intervention: You may request intervention where a decision has been made about you based solely on automated processing, and/or you may challenge that decision (this may happen in the context of our recruitment process where we collect information relating to whether or not a candidate has unspent criminal convictions).
• Access: You may request access to your personal data which enables you to receive a copy of the personal data that we hold about you and to check to see if we are processing it lawfully.
• Transfer: You may request that we transfer your personal data to you or a third party on our behalf. We will provide to you or the third party you have chosen, your personal data in a structured, commonly used, machine-readable format (Such as PDF – Portable Document Format).
• Rectification: You may request rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Erasure: You may request erasure of the personal data that we hold about you. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you if applicable at the time of your request.
• Object: You may object to how we are processing your personal data where we are relying on our legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data direct marketing purposes. In same cases we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
• Restriction: You may request that we restrict how we process your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios. (A) If you want us to establish the data’s accuracy. (B) Where our use of the data is unlawful but you do not want us to erase it. (C) Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. Or (D) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use and process it.
• Withdrawal Of Consent: Where we have relied on your consent to process your personal data you will have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before or during your withdrawal of consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time of your notice of withdrawal of consent.